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                          DEPARTMENT OF DEFENSE 
         DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
 
In the matter of: ) 
 ) 
  )  ISCR Case No. 15-05277 
  )   
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: Pamela C. Benson, Esq., Department Counsel 
For Applicant: Pro se 
 
 
August 20, 2018 
______________ 
 
Decision 
______________ 
 
 
MOGUL, Martin H., Administrative Judge: 
 
Statement of the Case 
 
On March 10, 2016, in accordance with Department of Defense (DoD) Directive 
5220.6, as amended (Directive), the DoD issued Applicant a Statement of Reasons 
(SOR) alleging facts that raise security concerns under Guidelines F and E.1 (Item 1.) 
The SOR further informed Applicant that, based on information available to the 
government, DoD adjudicators could not make the preliminary affirmative finding it is 
clearly consistent with the national interest to grant or continue Applicant’s national 
security eligibility. 
 
 On June 21, 2016, and July 25, 2016, Applicant submitted written replies to the 
SOR, and requested the case be decided on the written record in lieu of a hearing. 
(Item 1.)  On November 15, 2016, Department Counsel issued the Department's written 
case. A complete copy of the file of relevant material (FORM) was provided to 
                                                          
1 I considered the previous Adjudicative Guidelines, effective September 1, 2006, as well as the new 
Adjudicative Guidelines, effective June 8, 2017. My decision would be the same if the case was 
considered under the previous Adjudicative Guidelines, effective September 1, 2006. 
 
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Applicant. In the FORM, Department Counsel offered five documentary exhibits. (Items 
1-5.) Applicant was given the opportunity to file objections and submit material in 
refutation, extenuation, or mitigation. A response was due on December 22, 2016. 
Applicant submitted no additional documents. The case was assigned to this 
Administrative Judge on October 21, 2017. Based upon a review of the pleadings and 
exhibits, eligibility for access to classified information is denied. 
 
Findings of Fact 
 
 After a thorough and careful review of the pleadings, and exhibits, I make the 
following findings of fact:  
 
Applicant is 32 years old. She is unmarried, and she has no children. She 
received a Bachelor’s degree in 2009. Applicant is employed as an Analyst by a 
defense contractor, and she seeks a DoD security clearance in connection with her 
employment in the defense sector. (Item 2.) 
 
Guideline F, Financial Considerations  
 
 The SOR lists 21 allegations (1.a. through 1.u.) regarding financial difficulties, 
specifically concerning delinquent debts, under Adjudicative Guideline F. The debts total 
approximately $74,000. All of the debts were established by Items 3 and 4.  
 
1.a. This overdue debt is cited in the SOR for a delinquent account in the amount 
of $536. Applicant admitted this debt in her RSOR, and she wrote that she is currently 
on a payment plan with this account. (Item 1.) No independent evidence has been 
introduced to establish that this debt has been resolved or reduced.  
 
1.b. This overdue debt is cited in the SOR for a delinquent account in the amount 
of $384 Applicant admitted this debt in her RSOR. She wrote that this account has been 
paid off, and she will submit a bank account receipt upon request. (Item 1.)No 
independent evidence has been introduced to establish that this debt has been resolved 
or reduced. 
   
1.c. This overdue debt is cited in the SOR for a delinquent account in the amount 
of $424, with a balance of $4,524. Applicant admitted this debt in her RSOR, and she 
wrote that she is currently on a payment plan with this account. (Item 1.) No 
independent evidence has been introduced to establish that this debt has been resolved 
or reduced.  
   
1.d. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $1,001, with a balance of $22,629. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. Attached to her RSOR 
was a letter from this creditor which establishes that she received a forbearance for the 
debts to this creditor, and that a payment plan was in place for Applicant to pay monthly 
payments of $184 and $199, each for 120 months, to resolve these debts. (Item 1.) No 
 
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independent evidence has been introduced to establish that this debt has been resolved 
or reduced or that any payments were made. All of the subsequent debts listed below 
as 1.e. through 1.m., were to the same creditor as 1.d., for Applicant's student loans and 
the same payment plan applies to each one. 
            
1.e. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $1,162, with a balance of $24,704. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. (Item 1.) See 1.d., 
above. No independent evidence has been introduced to establish that this debt has 
been resolved or reduced or that any payments were made.    
   
1.f. This overdue debt is cited in the SOR for a delinquent student loan account in 
the amount of $508, with a balance of $10,243. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. (Item 1.) See 1.d., 
above. No independent evidence has been introduced to establish that this debt has 
been resolved or reduced or that any payments were made.    
  
1.g. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $719, with a balance of $15,296. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. (Item 1.)  See 1.d., 
above. No independent evidence has been introduced to establish that this debt has 
been resolved or reduced or that any payments were made.   
 
1.h. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $416, with a balance of $8,860. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. (Item 1.) See 1.d., 
above. No independent evidence has been introduced to establish that this debt has 
been resolved or reduced or that any payments were made.  
  
1.i. This overdue debt is cited in the SOR for a delinquent student loan account in 
the amount of $138, with a balance of $2,935. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. (Item 1.)  See 1.d., 
above. No independent evidence has been introduced to establish that this debt has 
been resolved or reduced or that any payments were made.     
 
1.j. This overdue debt is cited in the SOR for a delinquent student loan account in 
the amount of $373, with a balance of $7,732. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. (Item 1.)  See 1.d., 
above.  No independent evidence has been introduced to establish that this debt has 
been resolved or reduced or that any payments were made. 
 
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1.k. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $149, with a balance of $3,101. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. (Item 1.)  See 1.d., 
above. No independent evidence has been introduced to establish that this debt has 
been resolved or reduced or that any payments were made.   
    
1.l. This overdue debt is cited in the SOR for a delinquent student loan account in 
the amount of $292, with a balance of $6,266. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. (Item 1.)  See 1.d., 
above. No independent evidence has been introduced to establish that this debt has 
been resolved or reduced or that any payments were made.     
 
1.m. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $146, with a balance of $3,133. Applicant admitted this debt in her 
RSOR. She wrote that a forbearance was processed on this student loan to cover 
payments, and she is currently on an approved payments plan. (Item 1.) See 1.d., 
above. No independent evidence has been introduced to establish that this debt has 
been resolved or reduced or that any payments were made.     
 
1.n. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $9,378. Applicant admitted this debt in her RSOR. She wrote that a 
forbearance was processed on this student loan to cover payments, and she is currently 
on an approved payments plan. Attached to her RSOR was a letter from this creditor 
which establishes that she received three disbursements from this creditor in 2004, 
2005, and 2006, and the creditor has set up new payment plans for her to pay these 
three debts over the course of 119 months. (Item 1.) No independent evidence has 
been introduced to establish that this debt has been resolved or reduced or that any 
payments were made. 
 
1.o. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $36,403. Applicant admitted this debt in her RSOR. She wrote that a 
forbearance was processed on this student loan to cover payments, and she is currently 
on an approved payments plan. This is the same creditor as 1.n., above and the same 
payment plan applies. (Item 1.) No independent evidence has been introduced to 
establish that this debt has been resolved or reduced or that any payments were made. 
 
1.p. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $150, with a balance of $46,795. Applicant admitted this debt in her 
RSOR, and she wrote that she is currently on a payment plan with this account. (Item 
1.)  No independent evidence has been introduced to establish that this debt has been 
resolved or reduced. 
 
1.q. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $488, with a balance of $43,735. Applicant admitted this debt in her 
RSOR, and she wrote that she is currently on a payment plan with this account. (Item 
 
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1.) No independent evidence has been introduced to establish that this debt has been 
resolved or reduced. 
 
1.r. This overdue debt is cited in the SOR for a delinquent student loan account 
in the amount of $20,970. Applicant admitted this debt in her RSOR. She wrote that this 
account was sold to another entity and she is currently negotiating payment 
arrangements. (Item 1.) No independent evidence has been introduced to establish that 
this debt has been resolved or reduced. 
 
1.s. This overdue debt is cited in the SOR for a delinquent account in the amount 
of $490, with a balance of $4,836. Applicant admitted this debt in her RSOR, and she 
wrote that she is on a payment plan with this account. (Item 1.) No independent 
evidence has been introduced to establish that this debt has been resolved or reduced. 
 
1.t. This overdue debt is cited in the SOR for a delinquent account in the amount 
of $154. Applicant admitted this debt in her RSOR. She wrote that this account has 
been paid off, and she will submit a bank account receipt upon request. (Item 1.) No 
independent evidence has been introduced to establish that this debt has been resolved 
or reduced. 
 
1u. This overdue debt is cited in the SOR for a delinquent account in the amount 
of $39. Applicant denied this debt in her RSOR. She wrote that she was not aware of 
this account, and that she has not lived at the place from which this debt originated for 
almost 10 years. (Item 1.) No independent evidence has been introduced to establish 
that this debt has been resolved or reduced. 
 
Applicant did not provide any reasons for her delinquent debts on her RSOR. 
(Item 1.) Also, as reviewed above, no Post-FORM documents were submitted as to the 
status of her overdue debts. Finally, no evidence was offered to show that Applicant will 
be able to responsibly stay current with all of her more recent debts.   
 
Guideline E, Personal Conduct  
 
 The SOR lists one allegation (2.a.) regarding Personal Conduct, under 
Adjudicative Guideline E. 
 
2.a. The SOR alleges that Applicant deliberately falsified facts on an Electronic 
Questionnaires for Investigations Processing (e-QIP) that she executed on February 19, 
2015. (Item 2.) She was asked questions about her finances, including: In the last seven 
years, had she had a judgment entered against her; had she defaulted on any type of 
loan; had any of her bills been turned over to a collection agency; had any account been 
suspended, charged off or cancelled for failing to pay as agreed, had she been over 120 
days delinquent on any debt; and, was she currently over 120 delinquent on any debt?   
Applicant answered “No,” to all of these questions, and she failed to disclose her 
defaulted or delinquent student loan accounts, collection debts, and charged off debts 
as set forth under paragraph 1, above.  (Item 2.)  
 
 
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Department Counsel wrote on the FORM that Applicant denied allegation 2.a. 
However, on my copy of the RSOR, Applicant failed in her RSOR to address her failure 
to respond truthfully to the e-QIP. Clearly, at the time that Applicant completed her e-
QIP, she had charged-off student loans and delinquent debts with other collection 
agencies, as established in paragraph 1, above. There is no reasonable explanation for 
her failure to cite any of her overdue and delinquent debts.   
 
Policies 
 
 When evaluating an applicant’s suitability for a security clearance, the 
administrative judge must consider the adjudicative guidelines (AG). In addition to brief 
introductory explanations for each guideline, the adjudicative guidelines list potentially 
disqualifying conditions and mitigating conditions, which are to be used in evaluating an 
applicant’s eligibility for access to classified information. 
 
These guidelines are not inflexible rules of law. Instead, recognizing the 
complexities of human behavior, administrative judges apply the guidelines in 
conjunction with the factors listed in AG ¶ 2 describing the adjudicative process. The 
administrative judge’s overarching adjudicative goal is a fair, impartial, and 
commonsense decision. According to AG ¶ 2(a), the entire process is a conscientious 
scrutiny of a number of variables known as the whole-person concept. The 
administrative judge must consider all available, reliable information about the person, 
past and present, favorable and unfavorable, in making a decision. 
 
The protection of the national security is the paramount consideration. AG ¶ 2(b) 
requires that “[a]ny doubt concerning personnel being considered for national security 
eligibility will be resolved in favor of the national security.” In reaching this decision, I 
have drawn only those conclusions that are reasonable, logical, and based on the 
evidence contained in the record.  
 
Under Directive ¶ E3.1.14, the Government must present evidence to establish 
controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, the “applicant is 
responsible for presenting witnesses and other evidence to rebut, explain, extenuate, or 
mitigate facts admitted by the applicant or proven by Department Counsel, and has the 
ultimate burden of persuasion as to obtaining a favorable clearance decision.”  
 
 A person who applies for access to classified information seeks to enter into a 
fiduciary relationship with the Government predicated upon trust and confidence. This 
relationship transcends normal duty hours and endures throughout off-duty hours. The 
Government reposes a high degree of trust and confidence in individuals to whom it 
grants access to classified information. Decisions include, by necessity, consideration of 
the possible risk the applicant may deliberately or inadvertently fail to protect or 
safeguard classified information. Such decisions entail a certain degree of legally 
permissible extrapolation as to potential, rather than actual, risk of compromise of 
classified information. 
 
 
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Section 7 of Executive Order (EO) 10865 provides that adverse decisions shall 
be “in terms of the national interest and shall in no sense be a determination as to the 
loyalty of the applicant concerned.” See also EO 12968, Section 3.1(b) (listing multiple 
prerequisites for access to classified or sensitive information).  
 
Analysis 
 
Guideline F, Financial Considerations 
 
 The security concern relating to the guideline for Financial Considerations is set 
out in AG ¶ 18: 
 
Failure to live within one's means, satisfy debts, and meet financial 
obligations may indicate poor self-control, lack of judgment, or 
unwillingness to abide by rules and regulations, all of which can raise 
questions about an individual's reliability, trustworthiness, and ability to 
protect classified or sensitive information. Financial distress can also be 
caused or exacerbated by, and thus can be a possible indicator of, other 
issues of personnel security concern such as excessive gambling, mental 
health conditions, substance misuse, or alcohol abuse or dependence. An 
individual who is financially overextended is at greater risk of having to 
engage in illegal or otherwise questionable acts to generate funds. 
Affluence that cannot be explained by known sources of income is also a 
security concern insofar as it may result from criminal activity, including 
espionage.  
 
  The guideline notes several conditions that could raise security concerns under 
AG ¶ 19. The evidence has established that Applicant has had many delinquent debts 
for several years. No independent evidence was introduced to prove that any of these 
debts have been resolved. The evidence is sufficient to raise disqualifying conditions (a) 
and (c) as potentially applicable in this case:   
 
(a) inability to satisfy debts; 
 
(b) unwillingness to satisfy debts regardless of the ability to do so; 
 
(c) a history of not meeting financial obligations; 
 
(d) deceptive or illegal financial practices such as embezzlement, 
employee theft, check fraud, expense account fraud, mortgage fraud, filing 
deceptive loan statements and other intentional financial breaches of trust; 
 
(e) consistent spending beyond one's means or frivolous or irresponsible 
spending, which may be indicated by excessive indebtedness, significant 
negative cash flow, a history of late payments or of non-payment, or other 
negative financial indicators; 
 
 
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(f) failure to file or fraudulently filing annual Federal, state, or local income 
tax returns or failure to pay annual Federal, state, or local income tax as 
required; 
 
(g) unexplained affluence, as shown by a lifestyle or standard of living, 
increase in net worth, or money transfers that are inconsistent with known 
legal sources of income; 
 
(h) borrowing money or engaging in significant financial transactions to 
fund gambling or pay gambling debts; and 
 
(i) concealing gambling losses, family conflict, or other problems caused 
by gambling.  
 
 AG ¶ 20 provides conditions that could mitigate security concerns. I considered 
all of the mitigating conditions under AG ¶ 20 including: 
 
(a) the behavior happened so long ago, was so infrequent, or occurred 
under such circumstances that it is unlikely to recur and does not cast 
doubt on the individual's current reliability, trustworthiness, or good 
judgment; 
 
(b) the conditions that resulted in the financial problem were largely 
beyond the person's control (e.g., loss of employment, a business 
downturn, unexpected medical emergency, a death, divorce or separation, 
clear victimization by predatory lending practices, or identity theft), and the 
individual acted responsibly under the circumstances; 
 
(c) the individual has received or is receiving financial counseling for the 
problem from a legitimate and credible source, such as a non-profit credit 
counseling service, and there are clear indications that the problem is 
being resolved or is under control; 
(d) the individual initiated and is adhering to a good-faith effort to repay 
overdue creditors or otherwise resolve debts; 
 
(e) the individual has a reasonable basis to dispute the legitimacy of the 
past-due debt which is the cause of the problem and provides 
documented proof to substantiate the basis of the dispute or provides 
evidence of actions to resolve the issue; 
 
(f) the affluence resulted from a legal source of income; and 
 
(g) the individual has made arrangements with the appropriate tax 
authority to file or pay the amount owed and is in compliance with those 
arrangements. 
 
 
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The credit report, dated February 12, 2016, establishes that Applicant's 10 
student loans with a loan servicing company were delinquent, her two student loans to 
another creditor were charged-off, her account with a credit company was charged off, 
she was delinquent on a credit card, and she had a collection account with one her 
places of residence. Finally it was established that her other student loans were still 
delinquent. (Item 4.) Therefore, I do not find that any of the mitigating factors under AG 
¶ 20 are applicable in this case, and I find against Applicant under Guideline F. 
 
Guideline E, Personal Conduct 
 
 The security concern relating to the guideline for Personal Conduct is set out in 
AG ¶ 15: 
 
Conduct involving questionable judgment, lack of candor, dishonesty, or 
unwillingness to comply with rules and regulations can raise questions 
about an individual's reliability, trustworthiness, and ability to protect 
classified or sensitive information. Of special interest is any failure to 
cooperate or provide truthful and candid answers during national security 
investigative or adjudicative processes.  
 
  The guideline notes several conditions that could raise security concerns under 
AG ¶ 16. An Applicant may not be aware of every delinquent debt she has, but 
Applicant failed to cite any of the debts listed on the SOR under Guideline F, and she 
provided no reasonable explanation for her failure to furnish honest answers. I find that 
the evidence is sufficient to raise disqualifying condition (a) in this case:   
 
(a) deliberate omission, concealment, or falsification of relevant facts from 
any personnel security questionnaire, personal history statement, or 
similar form used to conduct investigations, determine employment 
qualifications, award benefits or status, determine national security 
eligibility or trustworthiness, or award fiduciary responsibilities; 
 
(b) deliberately providing false or misleading information; or concealing or 
omitting information, concerning relevant facts to an employer, 
investigator, security official, competent medical or mental health 
professional involved in making a recommendation relevant to a national 
security eligibility determination, or other official government 
representative; 
 
(c) credible adverse information in several adjudicative issue areas that is 
not sufficient for an adverse determination under any other single 
guideline, but which, when considered as a whole, supports a whole-
person assessment of questionable judgment, untrustworthiness, 
unreliability, lack of candor, unwillingness to comply with rules and 
regulations, or other characteristics indicating that the individual may not 
properly safeguard classified or sensitive information; 
 
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(d) credible adverse information that is not explicitly covered under any 
other guideline and may not be sufficient by itself for an adverse 
determination, but which, when combined with all available information, 
supports a whole-person assessment of questionable judgment, 
untrustworthiness, unreliability, lack of candor, unwillingness to comply 
with rules and regulations, or other characteristics indicating that the 
individual may not properly safeguard classified or sensitive information. 
This includes, but is not limited to, consideration of: 
 
(1) untrustworthy or unreliable behavior to include breach of 
client confidentiality, release of proprietary information, 
unauthorized release of sensitive corporate or government 
protected information; 
 
(2) any disruptive, violent, or other inappropriate behavior; 
 
(3) a pattern of dishonesty or rule violations; and 
 
(4) evidence of significant misuse of Government or other 
employer's time or resources; 
 
(e) personal conduct, or concealment of information about one's conduct, 
that creates a vulnerability to exploitation, manipulation, or duress by a 
foreign intelligence entity or other individual or group. Such conduct 
includes: 
 
(1) engaging in activities which, if known, could affect the 
person's personal, professional, or community standing; 
 
(2) while in another country, engaging in any activity that is 
illegal in that country; and 
 
(3) while in another country, engaging in any activity that, 
while legal there, is illegal in the United States; 
 
(f) violation of a written or recorded commitment made by the individual to 
the employer as a condition of employment; and 
 
(g) association with persons involved in criminal activity. 
 
 Applicant did not furnish the Government with any information about her 
delinquent debts on her e-QIP. Nor did she provide an explanation for her failure to 
include information to the Government about her significant past-due and delinquent 
debts. AG ¶ 17 provides conditions that could mitigate security concerns. I considered 
all of the mitigating conditions under AG ¶ 17 listed below, but did not find that any of 
them are applicable in this case:  
 
 
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(a) the individual made prompt, good-faith efforts to correct the omission, 
concealment, or falsification before being confronted with the facts; 
 
(b) the refusal or failure to cooperate, omission, or concealment was 
caused or significantly contributed to by advice of legal counsel or of a 
person with professional responsibilities for advising or instructing the 
individual specifically concerning security processes. Upon being made 
aware of the requirement to cooperate or provide the information, the 
individual cooperated fully and truthfully; 
 
(c) the offense is so minor, or so much time has passed, or the behavior is 
so infrequent, or it happened under such unique circumstances that it is 
unlikely to recur and does not cast doubt on the individual's reliability, 
trustworthiness, or good judgment; 
 
(d) the individual has acknowledged the behavior and obtained counseling 
to change the behavior or taken other positive steps to alleviate the 
stressors, circumstances, or factors that contributed to untrustworthy, 
unreliable, or other inappropriate behavior, and such behavior is unlikely 
to recur; 
 
(e) the individual has taken positive steps to reduce or eliminate 
vulnerability to exploitation, manipulation, or duress; 
 
(f) the information was unsubstantiated or from a source of questionable 
reliability; and 
 
(g) association with persons involved in criminal activities was unwitting, 
has ceased, or occurs under circumstances that do not cast doubt upon 
the individual's reliability, trustworthiness, judgment, or willingness to 
comply with rules and regulations. 
 
The Government relies heavily on the honesty and integrity of individuals seeking 
access to our nation’s secrets. When such an individual intentionally falsifies or omits 
material facts, it is extremely difficult to conclude that she nevertheless possesses the 
judgment, and honesty necessary for an individual given a clearance. Therefore, I find 
against Applicant under Guideline E. 
 
Whole-Person Concept 
 
 Under the whole-person concept, the administrative judge must evaluate an 
applicant’s eligibility for a security clearance by considering the totality of the applicant’s 
conduct and all relevant circumstances. The administrative judge should consider the 
nine adjudicative process factors listed at AG ¶ 2(d):  
 
(1) the nature, extent, and seriousness of the conduct; (2) the 
circumstances surrounding the conduct, to include knowledgeable 
 
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participation; (3) the frequency and recency of the conduct; (4) the 
individual’s age and maturity at the time of the conduct; (5) the extent to 
which participation is voluntary; (6) the presence or absence of 
rehabilitation and other permanent behavioral changes; (7) the motivation 
for the conduct; (8) the potential for pressure, coercion, exploitation, or 
duress; and (9) the likelihood of continuation or recurrence. 
 
Under AG ¶ 2(c), the ultimate determination of whether to grant eligibility for a security 
clearance must be an overall commonsense judgment based upon careful consideration 
of the guidelines and the whole-person concept.  
 
I considered the potentially disqualifying and mitigating conditions in light of all 
facts and circumstances surrounding this case. I have incorporated my comments under 
Guidelines F and E in my whole-person analysis.  
 
Overall, the record evidence leaves me with significant questions and doubts as 
to Applicant’s eligibility and suitability for a security clearance. For all these reasons, I 
conclude Applicant has not mitigated the Financial Considerations and Personal 
Conduct security concerns under the whole-person concept.  
 
Formal Findings 
 
 Formal findings for or against Applicant on the allegations set forth in the SOR, 
as required by ¶ E3.1.25 of the Directive, are: 
 
Paragraph 1, Guideline F:   AGAINST APPLICANT 
 
  Subparagraph 1.a.:    Against Applicant 
Subparagraph 1.b.:    Against Applicant 
Subparagraph 1.c.:    Against Applicant 
Subparagraph 1.d.:    Against Applicant 
Subparagraph 1.e.:    Against Applicant 
Subparagraph 1.f.:    Against Applicant 
Subparagraph 1.g.:    Against Applicant 
Subparagraph 1.h.:    Against Applicant 
Subparagraph 1.i.:    Against Applicant 
Subparagraph 1.j.:    Against Applicant 
Subparagraph 1.k.:    Against Applicant 
Subparagraph 1.l.:    Against Applicant 
Subparagraph 1.m.:    Against Applicant 
Subparagraph 1.n.:    Against Applicant 
Subparagraph 1.o.:    Against Applicant 
Subparagraph 1.p.:    Against Applicant 
Subparagraph 1.q:    Against Applicant 
Subparagraph 1.r.:    Against Applicant 
Subparagraph 1.s:    Against Applicant 
 
 
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Subparagraph 1.t.:    Against Applicant 
Subparagraph 1.u.:    Against Applicant 
 
Paragraph 2, Guideline E:   AGAINST APPLICANT 
 
  Subparagraph 2.a.:    Against Applicant 
 
Conclusion 
 
 In light of all of the circumstances presented by the record in this case, it is not 
clearly consistent with the national interest to grant Applicant national security eligibility 
for a security clearance. Eligibility for access to classified information is denied. 
 
 
 
 
Martin H. Mogul 
Administrative Judge